Message-ID: <15816917.1075853231963.JavaMail.evans@thyme>
Date: Fri, 1 Dec 2000 04:02:00 -0800 (PST)
From: gfergus@brobeck.com
To: richard.b.sanders@enron.com, sbishop@gibbs-bruns.com, msmith1@enron.com, 
	robert.c.williams@enron.com
Subject: San Diego Case Status Report
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Here are the results of our efforts since our last report:

Counsel Interviews:

 Charles Dick
  4:00 p.m.  (he is still waiting for an Orange County jury)
   He is working on clearing conflicts.
   Various offices of Baker have been contacted  for
purposes of this case by:
    NRG, Reliant, Williams, Duke
 David Noonan & Michael Kirby
  Available but not scheduled.  He is working on clearing the
Southern California Edison potential    conflict.
 Michael Weaver
   Will not have conflict results done until Mondayh.
PGE, SDGE and others.  He is still in New York is part of the problem.  He
is available to meet if conflicts clear.  He understands that he needs to
get this done ASAP.
 Dan Lamb
  Available.
Al Stokes Counsel  List
 No action taken to date.
Experts
 Charles River
   Called Gordon Rausser and gave him Richard's contact
information in Houston and suggested he try to meet after meeting with Ken
Lay.
  NERA
   Called again.  Expect to hear back at 3:00 p.m.
today.
Preemption
 Enron's FERC filing today will directly address preemption unless it
is changed immediately.
Removal
 We believe that SEMPRA is a California Corporation with its
principle place of business in San Diego.   Source:  California
Secretary of State On Line Records- Lexis.  If SEMPRA has been served, there
may  be no way to remove based upon diversity unless we can show a sham
(unlikely here.)  If SEMPRA is not  served yet and the other served
defendants agree, maybe we could get removal.  If SEMPRA is later
served, factor in remand.
Election of Judges:
 We are still determining election cycle for Judge Meyer and Judge
Amos.
 According to one counsel that we interviewed, he believes that Judge
Meyer is a "dim bulb on the  chandelier" and Judge Amos is worse.


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